Gerry M. Griggs - Page 22

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          6, 1985).  Thus, section 274(d) overrides Cohan v. Commissioner,            
          39 F.2d 540, 543-544 (2d Cir. 1930), which allows the Court, in             
          some circumstances, to estimate a deductible expense.  See                  
          Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per                 
          curiam 412 F.2d 201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary             
          Income Tax Regs., supra.                                                    
               Although petitioner offered into evidence numerous receipts            
          in support of his travel, meals, and entertainment expenses, he             
          did not provide the additional documentation necessary to                   
          substantiate these expenses.  In particular, the receipts did not           
          show the business purpose behind the trips or meals.  In short,             
          there was no documentation or rationale behind such expenses                
          other than petitioner’s unsupported testimony that the Court                
          declines to accept.  Sec. 1.274-5T(a), Temporary Income Tax                 
          Regs., supra.  Respondent is sustained on this issue.                       
               On a separate Schedule C of petitioner’s 2000 income tax               
          return, petitioner claimed a deduction for expenses relating to             
          another activity called “Frexie”.  This was the name petitioner             
          ascribed to his purchase of the right to use a luxury suite at              
          Minute Maid Park in Houston, Texas, the home field for the                  
          Houston Astros major league baseball team, for a 3-year period              
          for $250,000.  The Frexie activity involved the selling or                  
          letting by petitioner of the use of the suite during Houston                
          Astros baseball games.  In exchange for a commitment to purchase            






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